Privacy Policy
Last updated: 08.12.25
1. General
We at SMARTGEN Ltd. (the «Company,» «We,» «Us,» or «Our«), are committed to protecting your («You,» «Your,» or «User”) personal data and Your privacy. This privacy policy (the “Policy”) provides You with information regarding the types of information collected, processed, and used by the Company and others on Our behalf to provide You with Our services (the “Services”) on Our websites: https://www.smartgenisrael.com/, https://www.rus.smartgenisrael.com/, https://smartgen-global.com/, https://smartgeninvest.com/login/, https://smartgen-realty.com/ , https://smartgen-promo.com/ and by providing you with additional professional services.
2. The Scope
This Policy describes what kind of Personal Data the Company collects about natural persons, and how it collects it, uses it, shares it with third parties, secures it, processes it, etc.
This Policy is part of and should be read in conjunction with our Terms of Use (the “Terms”).
In this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.
In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.
3. When do We collect information about You?
3.1. We may collect Personal Data about You in the following circumstances:
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When You visit Our website;
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When You Share Personal Data with Us through our contact form;
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When You interact with Us in any manner, including by sending Us messages through chat tools embedded on our website, or through third-party messaging applications;
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When You use or receive any of Our services, including financial or investment management, advisory or related services;
3.2. You are not obligated to provide Us with any Personal Data about You. However, in some instances, not providing such Personal Data may prevent or limit Us from providing You with the Services You requested Us to provide You, in part or in whole, and may prevent or limit Your use of the Services or a part thereof.
3.3. When You provide Us with any type of Personal Data during Your use of Our Services, you are responsible for making sure You have the authorization and permission legally required to share this Personal Data with Us.
4. What Types of Information Do We collect?
We (or others on Our behalf) may collect the following types of Personal Data about You:
4.1. Communication information — When you contact Us, through any channel, including our contact form, chat tools embedded on our website, email, phone, or social media networks, or when You subscribe to Our Newsletter, You may provide Us with Your name, certain contact information (such as email address and phone), and the content of Your communication with Us.
4.2. Website usage information — When You visit our website, We may automatically collect limited technical information on your online activity log, such as session replay, analytics, web traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, operating system information, Your device information, crash reports and type of browser used, information regarding the device You used, including the hardware model, operating system and version and other device identifiers). Some of this information may not identify You personally and therefore does not constitute Personal Data.
4.3. Service and financial information – If/when You use or receive Our services, We may collect information necessary to provide such services and comply with legal requirements, including information about Your financial profile, investment preferences, portfolio holdings and transactions, source of funds, tax and residency status, and other information You choose to provide to Us or that is required by applicable law. Some or all of this information may constitute Personal Data.
4.4. Aggregate Information — We may create statistical, aggregated, and anonymized data relating to our Users and Services for analytical purposes, including business development and Platform improvements. Aggregated data is derived from Personal Data and User Data but in its aggregated form it does not relate to or identify any particular client or individual or any specific user’s data.
You are responsible for ensuring the accuracy of the information You provide Us (or others on Our behalf). Inaccurate information or fa will affect Our ability to provide You with some of the Services, as well as Our ability to contact You as contemplated in this Policy.
5. The Purposes of the Processing of Personal Data
The Company processes Your Personal Data only in accordance with this Privacy Policy and applicable law, for the following purposes:
5.1. To respond to your queries, requests, and/or complaints, and provide customer support.
5.2. To communicate with you, including sending essential service-related messages (such as confirmations or responses to your contact requests).
5.3. To provide Our services to you, including onboarding, account administration, financial or investment management, reporting, and maintaining our ongoing business relationship with you as necessary.
5.4. For security, fraud prevention, and protecting the website and our operations.
5.5. In order to comply with any legal obligations or judicial or administrative orders to which the Company is subject as well as to protect Our interests, rights, and assets, or those of third parties, according to any law, regulation, or agreement, including any of Our terms and conditions and policies.
5.6. To send you marketing updates, promotions, or newsletters if you have provided your explicit consent.
6. Sharing of Personal Data
6.1. We respect Your Personal Data and privacy and therefore will not use or disclose it except in accordance with this Privacy Policy. We may share Personal Data about You with third parties solely for the following purposes:
6.1.1. Upon Your consent or instruction;
6.1.2. Third parties providing Us services necessary for operating, securing, and improving Our Services and Platform. These include: storage and hosting, data security services, analytics, technical and support services, marketing and CRM management, accounting and legal services, as well as research, analytical, and diagnostic service providers.
6.1.3. If we will be subject to an audit or a Due diligence process;
6.1.4. If we sell, assign, or transfer some or all of Our business or assets to a successor or acquirer, if We are acquired by or merge with a third party, or if We file for bankruptcy or become insolvent, or any other situation where Personal Data may be sold, assigned or transferred to a successor or acquirer;
6.1.5. To protect Our rights, property, and interest or those of third parties;
6.1.6. To fulfill Our legal or regulatory requirements or to comply with a court order.
7. Transfer of Personal Data abroad
7.1. Personal Data about You may be transferred to a third country (i.e. jurisdictions other than the one you reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about You and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.
8. Marketing Communications
8.1. We may send You marketing communications if You have provided Your explicit consent, as well as from third parties, either in connection with the Services or in connection with other products and services.
8.2. You may opt-out from receiving communications from Us by using the contact information provided in section 14 below, and/or by clicking on the unsubscribe link available in Our e-mails sent to You.
9. Cookies
9.1. We may use certain third-party services, such as analytics companies or companies delivering advertisements, which may use cookies or other technologies, and those practices and providers are subject to their own policies.
9.2. The Cookie (which is a small text file) is installed on the device via which You visit or access the Platform. The cookies allow Us to collect information about You and Your behavior, to improve Your user experience, to remember Your preferences and settings, and to customize and offer You products and services that may interest You. Cookies are also used to collect statistics and perform analytics.
9.3. Some of the cookies We use are session cookies, which are downloaded temporarily to Your device and last until You close Your web browser, while others are persistent cookies, which last on Your device after You cease browsing the Service and are used to help the Service remember You as a returning visitor when You return to the Service.
9.4. The cookies We may use have been classified according to their functionality, as follows:
Cookie / Service Name
Purpose
Privacy Policy
Facebook Pixel
Tracks conversions, measures campaign performance, and builds remarketing audiences.
Reddit Pixel
Measures campaign interactions and optimizes Reddit advertising performance.
Marketo Tracking
Tracks visitor behavior and form submissions for marketing automation.
Adobe Cloud Experience Privacy Information
Adobe Experience Cloud
Used for marketing attribution, campaign optimization, and analytics.
Google Analytics / GA4
Collects aggregated analytics data (page visits, behavior, device information).
Visitor Analytics
Provides insights about how visitors use the website (page views, visit duration, device type).
Google API
Supports Google services such as Fonts, Maps, authentication, and rendering.
Google Maps
Required to display embedded Google Maps components and ensure proper functionality.
Cloudflare Cookies
Improves speed, security, bot protection, and ensures legitimate access to the site.
Sentry (Error Monitoring)
Detects technical errors, monitors performance, and improves service stability.
Cloudflare Zaraz Consent
Stores user cookie preferences for services loaded through Cloudflare Zaraz.
OneTrust Consent
Stores cookie consent preferences and manages opt-in/opt-out settings.
Operational Cookies (Wix)
Essential for secure and proper website operation, including page loading, navigation, authentication, and form submission.
9.5. You can manage your cookies preferences directly through the privacy settings in your browser. You may, delete the existing cookies, prevent the creation of cookies, or click the setting that enables You to accept or deny the creation of a cookie every time that a cookie is detected. Please see below links to instructions on how to do this in respect of some of the most popular web browsers: Firefox; Internet Explorer; Google Chrome; Safari
9.6. Please note that disabling cookies may affect some or all of the Service’s features, and certain functionalities might not perform as intended.
10. Security
10.1. We have implemented suitable security policies, rules, and technical measures to protect and safeguard the Personal Data under Our control from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction.
10.2. Any transfer of Personal Data via the internet cannot be fully secured. Therefore, the Company cannot ensure the protection of Personal Data about you when transferred via the internet to us and shall not be liable for any direct or indirect damage that may arise as a result of such Links to Other Websites or usage of such.
11. Links to Other Websites
11.1. The Platform may contain links to websites and/or applications of third parties. Other websites and applications may also reference or link to Our Platform. We do not control such websites and applications, nor the collection and/or processing of Personal Data about You by such websites and applications, and thus We are not responsible for the privacy practices. This Policy does not apply to any actions taken via such websites and/or applications.
11.2. Whenever You access such third parties’ websites and/or applications, We recommend that You carefully review their privacy policies before using such websites and/or applications and before disclosing any Personal Data about You.
12. Your Rights in Respect of the Personal Data about You
12.1. Generally, You have the right to request that We provide You with confirmation as to whether Personal Data about You is being collected by Us, and to ask to review such data which we may retain about you.
12.2. Once reviewed, You may request that We delete, change, or update any Personal Data relating to You (for example, if You believe that Personal Data related to You is incorrect, You may ask to have it corrected or deleted – if made possible by applicable law).
12.3. These rights may be exercised by You personally, by a person authorized by You in writing, or by a legal guardian acting on Your behalf. To do so, please contact Us via the contact information provided herein.
12.4. Please note that nothing in this Privacy Policy prevents Us from retaining Personal Data where required for legal purposes or to comply with a legal obligation.
13. Changes to the Policy
We may change this Policy in Our sole discretion at any time. Any revisions to this Policy will be posted as an updated version accessible via the Platform home page. We recommend that You revisit this Policy regularly to be kept apprised of any such changes.
14. Contact Us
For any queries relating to this Policy and data protection, please contact Us at smartgen@smartgenisrael.com.